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HOW TO DEVELOP AND IMPLEMENT AN EFFECTIVE
COMPREHENSIVE SAFETY & HEALTH PROGRAM


The Occupational Safety and Health Administration (OSHA) has issued voluntary program management guidelines to encourage employers to do more than just comply with regulations to prevent occupational injuries and illnesses. An effective program looks beyond specific requirements of law to address all hazards. It seeks to prevent injuries and illnesses, whether or not compliance is an issue.

Major elements of an effective occupational safety and health program include:

Management Leadership/Commitment

  • Develop a policy clearly stating responsibilities for the program and the priority of safety and health in relation to other organizational values. Explain how this is communicated to employees.
  • Set goals for the safety and health program and develop measures to ensure that the goals of the program are met. Explain how this is communicated to employees.

  • Describe how top management is visibly involved in the safety and health program.

  • Assign responsibilities for all aspects of the program so that managers, supervisors and employees know what performance is expected of them.

  • Ensure that responsible parties have the authority and resources to meet expectations.

  • Describe the system used for holding line managers and supervisors accountable for safety and health and how that system is documented.

  • Indicate how employees are held accountable for safe and healthful actions.

  • Describe how you perform the evaluation. For example, who evaluates the program, at what time of the year, what are the deficiencies, what are the recommended improvements, how is the evaluation report distributed, and how people are held accountable to ensure the recommendations from the evaluation are accomplished?

Employee Involvement

  • Describe how employees will be involved in the structure and operation of the program and in decisions that affect the safety and health of the workplace. Provide specific information about employee involvement in decision making, such as problem resolution, hazard analyses, accident investigations, safety and health training, or evaluation of the safety and health program.
  • Describe hazard recognition training or other specific training for committee members.

Worksite Analysis

  • Identify all hazards by conducting baseline worksite surveys for safety and health and periodic comprehensive update surveys. Include an analysis of planned and new facilities, processes, materials, equipment and routine job hazards. Explain how new or significantly modified equipment, materials, processes, and facilities are analyzed for otential hazards prior to purchase and use.
  • Schedule regular site safety and health inspections, so that new or previously missed hazards and failures in hazard controls are identified. Include schedules and types of inspections, the qualifications of those conducting the inspections, and how corrections are tracked to completion.

  • Describe how results from analyses, such as job hazard analyses, are used in training employees to do their jobs safely and in planning and implementing the hazards correction and control program.

  • Describe how employees notify management when they observe conditions or practices that may pose safety and health hazards. The reporting system must include protection from reprisal, timely and adequate response, and correction of identified hazards.

  • Describe how "imminent danger" situations are reported by employees and handled by management.

  • Describe the system used to conduct accident and "near miss" incident investigations.

  • Describe training and/or guidance given to investigators; provide criteria used for deciding which accidents/incidents will be investigated; and describe how near-miss incidents are handled.

  • Describe the "lessons learned" process being used at the site and demonstrate root cause analyses.

  • Describe the system(s) used to conduct trend analyses of all data generated by the safety and health program, including employee reports of hazards, hazard assessment data, and injury and illness experience data.

Hazard Prevention and Control

  • Describe procedures you use for preventive maintenance of equipment. Include information on scheduling, and describe how the maintenance timetable is followed.
  • Discuss procedures that are in place to ensure that all current and potential hazards are corrected in a timely manner through engineering techniques, safe work practices, provisions of personal protective equipment; and administrative controls.

Safety and Health Training

  • Describe formal and informal safety and health training programs for employees. Specifically address how employees are taught to recognize hazards related to their jobs.
  • Describe how often and in what way courses are evaluated and updated.

  • Describe measures used to ensure that employees understand and retain course information.

  • Describe how frequently training is performed and what prompts repeat training.

  • Describe formal and informal safety and health training for supervisors.

  • Describe how top-level managers are trained in their safety and health responsibilities.